Travel agency fraud is an increasing source of FCPA violations. The recent GlaxoSmithKline investigation is a prime example of the risks travel agents can pose, especially in China but in other regions as well, and travel agent relationships will likely come under government scrutiny in the aftermath of the GSK matter. Preventing corruption schemes using travel agents as the conduit for bribes can be difficult, however, as travel agency fraud can be easily hidden. To assist companies in strengthening their compliance programs with regard to the use of travel agents, the Anti-Corruption Report is publishing a comprehensive three-part series on identifying and preventing corruption involving travel agents. This, the first article in the series, details how travel agency fraud is accomplished and examines the motivations underlying such fraud. The second article will outline industries that are at particular risk for travel agent-related corruption schemes, explain why travel agency fraud is so difficult to detect and provide tips for strengthening company control over travel agents. The final article in the series will offer five concrete suggestions for preventing and detecting such fraud. See also “Seven Lessons from China’s Bribery Investigation of GlaxoSmithKline
” (Aug. 7, 2013).